August Policy Trend Trail

INTRODUCTION

The August Policy Trend Trail examines policy developments aimed at improving Nigeria’s economic potential through consumer protection, digital infrastructure, and the operationalisation of existing policy frameworks. The policies considered span across various sectors such as real estate, corporate commercial, taxation, public, postal, and digital economy sectors. Notwithstanding the diversity of sectors, the policy analysis reveals a shared common thread: the need to address structural gaps that have long constrained Nigeria’s economic growth and reduced consumer confidence. This Policy Trail examines not only the substance of each reform, but also the practical implementation questions that will ultimately determine their impact.

POLICIES

THE INVITATION FOR IMPLEMENTATION OF INCENTIVES UNDER THE NIGERIA STARTUP ACT

The National Information Technology Development Agency (the “NITDA”) made a call for the implementation of the Nigeria Startup Act, 2022 (the “Act”), to ensure that the provisions of the Act are adequately administered and its objective of supporting the growth and scalability of Nigerian startups is met. The Act introduced a wide range of mechanisms, including but not limited to the establishment of the National Council for Digital Innovation and Entrepreneurship (the “Council”), a Startup Support and Engagement Portal, a Startup Labelling Regime and a range of fiscal, financing, regulatory and ecosystem incentives, all targeted at supporting the startup industry in Nigeria.

The application of the Act extends not only to labelled startups but also to organisations and establishments whose activities affect the creation, support and incubation of labelled startups. To qualify for a Startup Label (the “Label”) under the Act, a startup must:

1. be a sole proprietorship or partnership established, or a company incorporated under the Companies and Allied Matters Act, 2020;
2. have been incorporated or have been carrying on business for not more than 10 years;
3. be involved in innovation, development, production, improvement and commercialisation of a digital technology product or process;
4. not be a holding company or subsidiary of an existing company which is not registered as a startup;
5. have at least one Nigerian founder or co-founder who holds at least one-third of the shareholding; and
6. be a holder or repository of a product or process of digital technology, or the owner or author of a registered software.

The Label is formally issued upon successful completion of the prescribed application process. This Label is significant because it serves as the gateway to the incentives and benefits provided under the Act, including applicable tax and fiscal incentives, export and investor incentives, funding opportunities, regulatory support, access to sandboxes, intellectual property assistance and other startup ecosystem benefits.

Despite the incentives and opportunities provided under the Act, further measures are required to ensure that its full potential is realised and the benefits accruing from its implementation are effectively maximised. Consequently, the recent call by NITDA for coordination amongst more than 15 MDAs is significant as this will aid the operationalisation of the Act, which is structured as a cross-government framework with different institutions responsible for different aspects of the startup ecosystem. The Council’s statutory functions include harmonising laws and regulations affecting startups, monitoring implementation, and reviewing MDA’s policies and directives that may affect startup operations, establishment and investment.

By necessary implication, the MDAs are expected to coordinate their respective mandates to ensure that labelled startups can seamlessly access the incentives and protections provided under the Act. This requires each MDA to clearly identify the incentives and regulatory functions within its mandate, establish eligibility requirements and application procedures, provide designated channels for startups, share information with NITDA and other agencies, and eliminate unnecessary duplication or conflicting requirements.

This includes coordination with the following regulatory authorities;

1. Nigeria Revenue Service (NRS) on applicable tax incentives.
2. Corporate Affairs Commission (CAC) on incorporation.
3. Central Bank of Nigeria (CBN) and Securities and Exchange Commission (SEC) on financial and fintech regulation and regulatory sandboxes.
4. Nigerian Investment Promotion Commission (NIPC) on investment promotion.
5. National Office for Technology Acquisition and Promotion (NOTAP) on technology transfer.
6. Bank of Industry (BOI) and other financing institutions on funding and the relevant IP institutions on intellectual property protection.

Accordingly, NITDA’s renewed push should be viewed as an implementation and regulatory-coherence development, with the key policy question being whether the MDAs can establish clear institutional responsibilities and coordinated processes that make the statutory benefits genuinely accessible while resolving overlaps and inconsistencies, particularly those arising from the interaction between the Act and the post-2026 tax regime under the Nigeria Tax Act 2025.

NATIONAL AGRICULTURAL MECHANISATION POLICY AND INVESTMENT STRATEGY

The Federal Government has unveiled the National Agricultural Mechanisation Policy (the “NAMP” or “Policy”) and the National Agricultural Mechanisation Investment Strategy (“NAMIS” or “Strategy”) (collectively referred to as the “Instruments”). These Instruments were put in place to address Nigeria’s agricultural mechanisation deficit, improve agricultural productivity and attract sustainable private-sector investment across the agricultural value chain. The Instruments serve distinct but complementary purposes: the Policy provides the national direction and sets out the regulatory, institutional and operational framework for sector development, whereas the Strategy provides the investment pathway, translating the policy direction into bankable opportunities to mobilise the capital, technology and entrepreneurship required to build a commercially viable, public-private-sector-led mechanisation ecosystem. Collectively, they are designed to build a functioning national mechanisation ecosystem that connects machinery with finance, operators, maintenance, spare parts, digital systems, research, standards, farmers and markets.

Under the Instruments, mechanisation is defined broadly to cover land preparation, planting, irrigation, crop protection, harvesting, processing, storage, logistics, precision agriculture, digital technologies, financing, insurance, maintenance and after-sales services. A key feature of the Instruments is the proposed development of a “Mechanisation-as-a-Service” economy, under which farmers can access machinery and related services at a commercially viable rate and under a sustainably financed model, i.e., without bearing the full cost of equipment ownership and maintenance. The Strategy also envisages a mega tractor assembly plant with an annual capacity of 2,000–4,000 tractors, which is aimed at anchoring national food sovereignty. This development builds on the Renewed Hope National Agricultural Mechanisation Programme, under which the Government has commenced deployment of 2,000 tractors and more than 9,000 implements and spare parts.

Furthermore, the development presents significant opportunities for private investors, agricultural equipment manufacturers and importers, machinery leasing and mechanisation service providers, agribusinesses, financial institutions, logistics operators and agricultural technology companies. This is because the Instruments are designed to promote local production, create jobs, reduce dependence on importation and ultimately build a sustainable mechanised agricultural economy, which requires sustained private-sector participation to achieve.

The Government has outlined a shared implementation model under which the Federal Government provides policy, standards and coordination; the State Governments support access to land, infrastructure and local execution; private-sector actors invest and deliver services; financial institutions structure financing and risk-sharing mechanisms; whilst development partners and research institutions provide technical support for the agriculture ecosystem. The Federal Ministry of Agriculture and Food Security has also indicated that an Implementation Taskforce will be inaugurated, indicating a transition from policy formulation to implementation.

These Instruments create a range of regulatory, commercial and compliance considerations for private-sector participants, including those operating in the areas of investment structuring, public-private partnership and government contracting, agricultural equipment financing and leasing, tax and investment incentives, importation and standards, land and infrastructure arrangements, technology transfer, insurance, digital agriculture and regulatory compliance. The immediate policy question is whether the Government can translate the Strategy into bankable projects through clear implementing frameworks, financing mechanisms, institutional responsibilities and private-sector participation, thereby making mechanisation commercially viable and accessible to farmers.

NIGERIA’S PROPOSED DEVELOPERS HOUSING COMPLIANCE AND HOUSING FINANCE REFORM

In the July Policy Trend Trail, a succinct explanation was given to the proposed National Housing and Built Environment Regulation Policy, which proposed developers licence and professional registration of all ecosystem players in the real estate industry in Nigeria. Building on this, the Real Estate Developers Association of Nigeria (the “REDAN”) made a formal proposal to the Federal Ministry of Housing and Urban Development for the adoption of a Certificate of Professional Good Standing for real estate developers (the “Certificate”). The Certificate is intended to serve as a regulatory compliance obligation on all real estate developers in Nigeria.

In addition, the certification serves to confirm the corporate and beneficial ownership information of developers, verify development history, compliance, and disciplinary status and ensure that anti-money laundering compliance and professional standards are met. To maintain professional standards, REDAN proposed that the Certificate be issued annually as a developer practice certificate. This is intended to enforce continuous compliance, promote professional development, uphold ethical conduct and strengthen accountability across the industry. The overarching policy objective of this reform is the protection of real estate consumers and investors from the risks associated with poor property development, including real property fraud, building collapse and substandard construction.

Another reform and development in the real estate sector is the Federal Government’s proposal to establish a National Housing Finance Authority aimed at expanding affordable housing finance for Nigerians. The proposed authority forms part of the broader National Mortgage Industry Policy, which also targets the improvement of access to mortgage financing, repositioning of the Federal Mortgage Bank of Nigeria (the “FMBN”) and expansion of participation in the National Housing Fund (the “NHF”).

In a bid to advance accessibility and financial inclusion, workers in the informal sector, such as labourers, traders, and artisans, would be allowed to participate in the NHF with monthly contributions set at a minimum threshold of N5,000.00 (Five Thousand Naira only). While this is a welcome step toward broadening the contributor base, the fixed contribution threshold warrants scrutiny. Under the existing NHF Act, formal sector employees contribute 2.5% of their basic monthly salary, meaning that a salaried employee earning the national minimum wage contributes less than N2,000.00 (Two Thousand Naira only) per month. Therefore, setting a flat minimum of N5,000.00 (Five Thousand Naira only) for informal sector contributors creates a disproportionately higher burden on informal workers relative to formal minimum wage earners. This poses the risk of excluding the very population the policy seeks to accommodate. To resolve this tension between the policy’s inclusion objective and its financial structure, the Government may consider adopting a percentage-based or tiered contribution model for informal sector participants rather than a rigid fixed floor, alternatively the fixed floor can be set at N2,000.00 (Two Thousand Naira only) to match the contributions of formal minimum wage earners.

Although the government is actively taking steps to deepen mortgage penetration, reduce Nigeria’s housing deficit and restore investor and consumer confidence in the sector, the effectiveness of these reforms will depend on whether the contribution structures and institutional frameworks are calibrated to produce outcomes that are commensurate with the scale of Nigeria’s housing challenge.

NATIONAL DIGITAL ALPHANUMERIC POSTCODE SYSTEM

In August, 2026, the Nigerian Postal Service (NIPOST) and the Federal Ministry of Communications, Innovation and Digital Economy announced the introduction of a new digital postcode system aimed at improving the accuracy and standardisation of addresses across the country.

The new system will assign to every building a unique 11-character, GIS-enabled alphanumeric code (made up of State, LGA, District, Area and building). This system is expected to improve logistics, e-commerce, banking, and Know Your Customer (KYC) verification (via integration with the NIN platform) and strengthen emergency response and government service delivery.

The new code would replace the existing six-digit postcode system which has become largely nonfunctional and has created significant challenges for logistics and delivery businesses, as many dispatch and logistics operators currently rely heavily on verbal descriptions and informal landmarks to locate customers. This has also limited the number of consumers that businesses can effectively reach and has resulted in delayed deliveries and loss of parcels. The weakness of the existing system therefore creates a double burden: consumers face difficulties receiving goods and services, while businesses lose revenue and economic opportunities due to inefficient last-mile delivery.

Another issue that has been closely associated with the failure of the existing system is the inability to effectively carry out KYC verification due to constraints faced by institutions in confirming specific physical locations. The adverse effects of this include security concerns, slow emergency response, poor fraud prevention, and criminal investigations, especially where the inability to trace an address hinders investigations. Thus, a more precise digital addressing system like the alphanumeric code system could strengthen both service delivery, address traceability and national security.

Although implementation will be phased, with the first phase scheduled to commence on 1^st October, 2026, the success of the system will depend on the effectiveness of the nationwide integration of the system. Specifically, a concerted effort will be required to ensure that rural communities and settlements with limited digital infrastructure are not excluded.

THE NATIONAL SOFTWARE QUALITY ASSURANCE FRAMEWORK

In recent years, the rapid adoption of software across various sectors in Nigeria, coupled with rising incidents of system failures and cybersecurity vulnerabilities, particularly in the public sector, has elevated software development, deployment and governance to a major policy priority. In a bid to improve the quality of the software being rolled out and used in Nigeria, the National Information Technology Development Agency (“NITDA”) published the National Software Quality Assurance Framework (the “Framework”). This framework imposes structured standards for the development, testing and deployment of software in Nigeria.

The Framework focuses on promoting the improvement of the quality, security, reliability and performance of software systems, most especially those used in government and other regulated sectors. A major mechanism introduced by the framework is the formal quality assurance and testing requirements intended to reduce system failures, strengthen cybersecurity resilience, protect public and private investment in digital infrastructure and, most importantly, ensure continued and quality service delivery.

Furthermore, it creates some compliance expectations on developers and organisations that deploy digital solutions, such as obtaining IT project clearance and an independent third-party testing of any government software before wide adoption. This compliance expectation needs to be factored into a product’s development cycle and procurement processes. The goal of this Framework is to improve the trust and reliability that Nigerians have in digital services used for public service delivery and other major sectors i.e., banking, telecommunications, financial technology, etc.

From a policy front, the publication of this Framework reflects that Nigeria’s focus is shifting from technology expansion and adoption to ensuring that the technology being deployed in Nigeria meets a defined standard of security, reliability, and fitness for purpose. This shows an underlying understanding that technological expansion alone is insufficient to make Nigeria’s digital economy, infrastructure and service delivery better, rather the quality of the technology in use. Another policy question and observation which must be considered is whether owing to the fragmented technology ecosystem in Nigeria, the compliance obligations imposed by the Framework will be proportionate to the scale and capacity of the developers and organisation to which they apply, and not only the risk associated with a software.

Although the Framework is scheduled to take full effect by the second quarter of 2027, NITDA has indicated that a call for an expression of interest will be made for organisations interested in being licensed to provide independent third-party testing services.

THE GUIDELINES ON THE TAXATION OF VIRTUAL ASSETS

The Nigeria Tax Act, 2025 (the “Act”), introduced the formal taxation of digital and virtual assets. The Act provides a broad definition for digital assets that encompasses cryptocurrencies, non-fungible tokens (NFTs), and other virtual tokens. Also, by the combined reading of the Ninth Schedule to the Nigeria Tax Act 2025, Section 79 of the Nigeria Tax Administration Act 2025 (the “NTAA”) and its Fifth Schedule, there is a legislative grounding for taxation of virtual assets together with the registration, reporting and compliance obligation on virtual asset industry participants.

Upon the commencement of the Act and NTAA, there were questions on the administration of these provisions and in line with the presidential executive order on virtual assets coordination, the Nigeria Revenue Service (NRS) issued the Guidelines on the Taxation of Virtual Assets (the “Guidelines”), providing the administrative framework for implementing the virtual asset provisions of the Act and the NTAA.

The Guidelines are targeted at taxpayers, Virtual Asset Service Providers (VASPs), Peer-to-Peer (P2P) marketplace operators, tax professionals and individuals involved in virtual asset transactions, as the Federal Government seeks to strengthen tax compliance and broaden revenue collection from the digital economy. All individuals and institutions covered by the above highlighted scope have mandatory obligations to register as taxable persons, file returns, submit reports and maintain traceable records of their virtual asset activities. The Guidelines cover a broad range of activities, including cryptocurrencies, stablecoins, non-fungible tokens, tokenised assets, DeFi transactions, staking, mining, airdrops and token swaps, all grouped into 6 broad classifications.  The categories of tax payable are Income Tax payable by individuals, companies and non-residents, Value Added Tax (VAT) and Stamp Duty.

By the guidelines, VASPs and exchanges are required to withhold and remit applicable taxes in the digital asset being traded, rather than deducting fiat currency from a bank account, thereby integrating digital asset trading into the national revenue administration framework. Individuals and institutions that fail to enforce these withholding and reporting obligations face severe penalties starting at N10 Million for the first month of non-compliance, alongside a 40% penalty on any uncollected tax. Individual users who fail to register face an initial N50,000.00 (Fifty Thousand Naira only) fine plus monthly default penalties.

Following the publication of the Guidelines, the provision on the 1.5% stamp duty on token-to-fiat and fiat-to-token transactions has attracted considerable pushback from industry players. By the provision contained in Clause 6.3 of the Guidelines, a duty is vested in the transferee of a token to withhold a 1.5% stamp duty from the token credited to the transferee i.e. a buyer of Bitcoin, receives 0.35 BTC rather than 0.5 BTC after stamp duty is deducted. Ecosystem participants have raised a technical objection stating that most cryptocurrency transactions are valued in whole or fractional units rather than in naira profit figures, hence the 1.5% stamp duty effectively operates as a tax on transaction value rather than on profit. In addition, it has been argued that there is hardly a 1.5% profit margin on a single digital trade transaction.

The industry’s reaction raises a fundamental policy concern regarding the adequacy of stakeholder consultation prior to the issuance of the Guidelines. Whilst Nigeria’s move to formalise the taxation of virtual assets is consistent with global trends; the inclusion of a technically problematic provision that has attracted immediate and well-founded objections from the very market participants the Guidelines seek to regulate suggests that pre-issuance engagement may have been insufficient. The critical question is not whether the policy direction is right but whether the mechanisms chosen to implement it were subjected to adequate scrutiny before being made binding.

Owing to the foregoing, it is imperative to note that the strength of a regulatory instrument is not measured by the speed of its enactment nor by the sophistication of its drafting, but by the feasibility of its implementation. Provisions that are technically unworkable or economically irrational will in practice undermine voluntary compliance, frustrate the growing digital economy, drive participants/activity offshore, and erode the revenue base the Guidelines seek to expand. As such, the NRS is advised to issue clarification guidance on the stamp duty provision, while other regulators are encouraged to glean from this by ensuring that all policy-making fundamentals are employed before the issuance / publication of any policy.

THE NATIONAL DIGITAL CLOUD POLICY

Over the years, Nigeria’s ambition to build a strong digital economy has uncomfortably existed alongside a structural reality: a significant portion of the cloud infrastructure that Nigerian businesses, government agencies and startups depend on is hosted outside the country. The implication of this is that the revenue, jobs, data and leverage that are associated with hosting cloud infrastructure are vested in the country which hosts the same. To remedy this, the Federal Ministry of Communications, Innovation and Digital Economy (FMCIDE) released the National Digital Cloud Policy (the “Policy”), which is by far the Federal Government’s most deliberate attempt to maximise the prospects linked with digital economy in Nigeria.

This policy outlines a national approach to grow and govern Nigeria’s cloud computing and data infrastructure ecosystem. The central ambition is to reposition Nigeria from a consumer of foreign digital infrastructure into a regional hub that hosts, processes and exports cloud services to West Africa and the Sub-Saharan African market. To achieve this, it pursues four interlocking objectives: attracting private investment into data centres and cloud infrastructure through regulatory facilitation; technology transfer and export earnings support, positioning Nigeria as a preferred hosting and digital services destination for the region; modernising government service delivery by mandating a Cloud-First approach across all Ministries, Departments and Agencies with shared infrastructure and coordinated procurement; and establishing a proportionate digital sovereignty framework that classifies government and regulated data into four tiers, applying residency and control requirements only where genuinely necessary rather than as a blanket restriction on the market.

The Policy’s structural design reflects an emphasis on institutional coordination, as it explicitly assigns responsibilities: NITDA holds regulatory oversight and standards assurance; Galaxy Backbone leads operational delivery and government infrastructure aggregation; and the Bureau of Public Procurement ensures that cloud procurement aligns with public procurement requirements. A Sovereign Government Cloud Governance Committee, established by the Policy, is to be chaired by the Minister of the FMCIDE, and saddled with the responsibility of coordinating the implementation of the sovereignty framework. The separation of regulatory, operational and procurement functions across three distinct institutions is a deliberate design choice, intended to prevent the conflicts of interest and accountability gaps that have undermined previous digital governance arrangements.

The Policy has a phased implementation over a 24 (twenty-four) month period, with the first 6 (six) months focusing on establishing governance structures and conducting baseline audits; the middle phase activates the National Digital Marketplace and begins MDA cloud migrations; and the final phase scales regional expansion and digital service exports. Whether the Policy delivers its intended objectives will be measured against concrete indicators such as regional cloud capacity contracted from Nigeria, foreign exchange earnings from digital service exports and a functioning and secure government hosting system.

In conclusion, this Policy is notable not merely because of its content but the five policy questions it attempts to answer within a single framework: why the intervention is necessary, what specific problem it addresses, what the Government is committing to deliver, who is accountable for each component and how success will be measured, thus offering a structured and accountable framework for translating Nigeria’s digital economy ambitions into practical infrastructure outcomes.

THE NIGERIAN PORT ECONOMIC REGULATORY AGENCY ACT

In August, 2026, President Bola Ahmed Tinubu signed the Nigerian Port Economic Regulatory Agency Act (the “NPERAA”) into law. The NPERAA establishes the Nigerian Port Economic Regulation Agency (the “Agency”) and saddles it with the responsibility of overseeing the economic aspects of Nigeria’s ports.

Prior to the enactment of the NPERAA, the economic regulation of Nigeria’s ports fell within the regulatory oversight of the Nigerian Shippers’ Council. This mandate was derived from the Nigerian Shippers’ Council (Port Economic Regulator) Order, 2015 and the Nigerian Shippers’ Council (Port Economic) Regulations, 2015. However, the stance of the Nigerian Shippers’ Council as provided by these regulatory frameworks was considered undesirable as it left the Nigerian Shippers’ Council susceptible to legal challenges as to the scope and validity of its regulatory authority, particularly because its powers were conferred through a subsidiary legislation rather than being expressly established under an Act of Parliament.

By the enactment of the NPERAA, the Shippers Council Act of 1978 was repealed and the Agency has been established to take over the functions of the now-defunct Shippers’ Council. By the NPERAA, the Agency is saddled with these functions including but not limited to: administration and enforcement of the NPERAA; implementation of the economic regulatory framework and policies; periodic review of economic activities, monitoring of compliance by service providers in respect of port concessions; setting terms and conditions for the registration of service providers; advising the federal government on trends and matters; and conducting research into challenges faced by service providers.

The NPERAA also spells out the power of the Agency to make regulations and guidelines on matters within its scope, including tariffs, rates and charges. It gives the existing registration regime statutory footing and strengthens the consequences of noncompliance.

In addition, the NPERAA established a new fund from which the agency is expected to operate. This fund is to be credited with an initial Federal Government take-off grant, National Assembly appropriations, registration fees and dues, subscriptions and levies, fines, permitted gifts and grants, loans, investment, returns and a charge of 1% of the freight paid on every import into Nigeria.

Furthermore, there are also offences and penalties created under the NPERAA as well as a robust enforcement mechanism. On one hand, individuals who contravene the provisions of the NPERAA are liable to pay a fine of at least N1,000,000.00 (One Million Naira only) or imprisonment for at least one year, or both for first time offenders. Subsequent offenders face a fine of at least N2,000,000.00 (Two Million Naira only) or imprisonment for at least three years, or both. Corporate entities, on the other hand, face a fine of at least N5,000,000.00 (Five Million Naira only) for a first offence and at least N10,000,000.00 (Ten Million Naira only) for a subsequent offence

A policy concern with the enactment of the NPERAA is the issue of duplication of functions, which had earlier delayed the enactment of a new Act for the economic regulation of Nigeria’s ports system. When the bill was earlier proposed in 2024, it was called the “Nigerian Shipping and Port Economic Regulatory Agency” Bill, and there was a massive pushback against it as stakeholders believed that it would create a new government agency whose functions and jurisdiction would overlap with existing agencies in the maritime sector.

Of particular concern were the provisions that seemed to encroach on the domain of the Nigerian Maritime Administration and Safety Agency (the “NIMASA”) and the Nigerian Port Authority (the “NPA”). NIMASA raised concerns about provisions relating to shipping regulation, licenses, fees and charges, whilst the NPA raised concerns relating to being the regulatory landlord over the concessions operative in the Nigerian port system. These are issues that remain unanswered by the NPERAA because the functions as published reflects that there are competing interest between these agencies, which then imposes compliance constraints on operators within the port ecosystem.

In conclusion, the NPERAA makes great strides in providing greater legal footing for the future of Nigeria’s ports’ regulatory and economic future. However, its success will hinge strongly on its ability to delineate its regulatory functions from the NIMASA and the NPA.

CONCLUSION

The Policies released in August reveal a clear pattern in Nigeria’s reform landscape: government is increasingly using policy regulation as instruments to restructure markets, strengthen revenue mobilisation, expand digital and productive capacity, and direct investment towards priority sectors.

The developments across taxation, digital infrastructure, agriculture, housing and the startup ecosystem demonstrate that reform is becoming more consequential for businesses and regulated sectors, particularly as new frameworks reshape incentives, compliance expectations and the roles of public institutions. The immediate policy concern is therefore the quality of implementation: whether the emerging frameworks are sufficiently clear, coordinated and legally grounded to avoid regulatory overlap, uncertainty and unintended compliance burdens. Monitoring these developments at an early stage remains critical to identifying such issues before they crystallise into operational or regulatory risks.

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